# Informational Workshop

Regarding Amendments to Hazardous Waste Regulations
Mark M. Dennen, Christopher Shafer RIDEM/ Of

fice of Waste Management

# Purpose of Ammendments  To comply with 2012 Paint Statute

– Requires DEM to modify rules to allow Paint Collection Centers  To consider providing environmentally responsible regulatory relief to small businesses as part of Reg Flex review process  To update state rules relative to new federal regulations  To make regulations easier to read and follow

# Explanation of Process  Issuance of Public Notice 11/15/2013  Informal Workshop 12/9/2013 10:00

– Brief presentation on changes

– Opportunity for informal discussion

– Informal Discussions can continue after hearing  Formal Hearing (with transcription) 11:00

– All comments will be recorded by stenographer

– Department must formally respond in writing

– Department may not answer questions during hearing  Close of Public Comment Period 12/16/2013  DEM’s goal to have written response and final regulations filed in January 2014

# Significant Changes  

### Incorporation of specific Federal Rules no longer in separate section  

### Extensive Revision of Generators Rules 

### Addition of New Categories of Facilities

# Tiered Generator Status  2010 rules regulate all generators as Large Quantity.  2013 Draft contains recognition of Federal Generator Status

– Large Quantity Generator (LQG) >2200 lb/month

– Small Quantity Generator (SQG) > 220 lb/month

– Conditionally Exempt Small Quantity Generator (CESQG) <220 lb/month  Based on Federal Definitions for quantity  State only hazardous waste counts in calculations

# LQG  

### Most of current generator requirements retained  

### Includes Household Hazardous Waste Facilities as well as Community Collection and Paint Collection Centers

# SQG 

### Allowed 180 days storage (not 90)  

### Do not have to submit Contingency Plan to DEM  

### Does not need to submit biennial report  

### Some restrictions on quantity and types of storage vs. LQG

# CESQG  

### May store waste for 365 days  

### May self transport waste  

### May dispose of waste at Community Collection Centers or Paint Collection Centers  

### Same relief from Contingency Plan and Biennial Report as SQG

## CESQG federal exemptions not

recognized  

### May not dispose of Hazardous Waste in a Solid Waste Landfill  

### Must use manifest exempt for waste dropped off at Community Collection Center or Paint Collection Center  

### Must obtain USEPA ID number from DEM

# Paint Collection Centers  

### Required by RIGL 23-24.12  

### Paint Collection Centers

– Mostly Hardware stores

–Collect paint from CESQG and Households at no cost

–Collect latex and oil based paint

–Ship waste to treatment facility on BOL

–Classified as LQG  

### No fee but need EPA Id Number

# Community Collection Center  

### Household Hazardous Waste Facilities do not need this permit  

### Meant for collection of other hazardous wastes from homeowners **as well as**  **CESQG’s**  

### $2,000 permit fee 

### Also considered LQG

# Additional Changes  Deletion of Certain Rhode Island Hazardous Waste (R Codes)  Slightly toxic waste LD50 < 5000 mg/kg  Slightly flammable flash point <140 > 200  Slightly reactive  Added waste chemotherapy agents  Mercury containing waste unless treated as universal waste  Exempt Household Hazardous Waste Pharmaceutical to encourage Police Dept. collection

## Recent Federal Rules not Adopted or Restricted  

### Exclusion for Hazardous Secondary Materials in 40 CFR 261.2

– DSW rule not adopted  

### Lab Sinks Rule (40 CFR 262 Subpart K)

– Not adopted  

### Circuit board exclusion of 261.4(a)(14)

–Separate permitting process for circuit board shredding

# Other Federal Rules restricted  

### Disposal of solvent contaminated wipes proposed by USEPA as 40 CFR 261.4(b)(18) not adopted although exemption for laundered wipes is adopted  

### Manufactured gas plant waste exemption in 40 CFR 261.24(a) applies only to remediation waste  

### Household hazardous waste collection regulated as hazardous after collection

## Exempt Treatment by Generators spelled out in generator rules (as opposed to Facilities)  Treatment in Totally enclosed units  Treatment in Tanks and Containers  Evaporator Units

– Must obtain non-discharge permit

– Must not release to air

– Evaporators specifically defined to concentrate waste  Emergency treatment is specifically spelled out in the generator section  Wastewater treatment units

– May not treat concentrated waste; only for wastewaters

## Circuit Board Recycling Operations  

### Previous rule did not allow this  

### Must obtain Permit  

### $10,000 new permit, $5,000 renewal every 5 years  

### Must demonstrate:

– protection of workers,

–financial assurance,

–tracking,

–training

## Questions?

Concerns?  

### Hearing will commence at 11:00  

### Staff will stay after hearing for continued discussion